This policy is used to inform those whose personal data may be held by Hartington Town Quarter Parish Council how it is managed. It is a comprehensive document based on a template provided by the Derbyshire Association of Local Councils. As such it contains numerous references to forms of data collection and use which may not be used by Hartington Town Quarter Parish Council. However, it refers to these to explain how they would be managed should the need arise.
Hartington Town Quarter Parish Council’s Policy for compliance with the General Data Protection Regulation. This policy and its appendices set out policy that is specific to Hartington Town Quarter Parish Council.
3. Your personal data – what is it?
“Personal data” is any information about a living individual which allows them to be identified from that data (for example a name, photographs, videos, email address, or address). Identification can be by the personal data alone or in conjunction with any other personal data. The processing of personal data is governed by legislation relating to personal data which applies in the United Kingdom including the General Data Protection Regulation (the “GDPR) and other local legislation relating to personal data and rights such as the Human Rights Act.
4. Council information
5. What personal data might be collected?
•Names, titles, and aliases
•contact details such as telephone numbers, addresses, and email addresses; where they are relevant to the services provided by a council, or where you provide them to us, we may process demographic information such as gender, age, marital status, nationality, education/work histories, academic/professional qualifications, hobbies, family composition, and dependants;
• Where you pay for activities such as use of a hall, financial identifiers such as bank account numbers, payment card numbers, payment/transaction identifiers, policy numbers, and claim numbers;
• [The data we process may include sensitive personal data or other special categories of data such as racial or ethnic origin, mental and physical health, details of injuries, medication/treatment received, political beliefs, trade union affiliation, genetic data, biometric data, data concerning and sex life or sexual orientation].
• Website data - Is activity information (including user behaviour data) collected? e.g. o Information from synching with other software or services o Interaction with social media (functional and/or marketing) and what information is available? Information about payments. Access to social media profiles. Demographic information
• Information collected automatically from use of the service? e.g.
o Device information (nature of device and/ or identifiers)
o Log information (including IP address) o Location information (how is location collected/inferred) o Device sensor information o Site visited before arriving o Browser type and or OS o Interaction with email messages
• Information from other sources? (identify the sources) e.g. o Referral or recommendation programmes o Publicly accessible sources
• Information from cookies or similar technologies (incl. in-app codes) (including whether session or persistent) e.g. Essential login/authentication or navigation. Functionality – remember settings Performance & Analytics – user behaviour Advertising/retargeting. Any third party software served on users. Other
• Nature of any outbound communications with website users. Email. Telephone (voice). Telephone (text)
6. The council will comply with data protection law. This says that the personal data we hold about you must be:
• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Kept only as long as necessary for the purposes we have told you about.
• Kept and destroyed securely including ensuring that appropriate technical and security measures are in place to protect your personal data to protect personal data from loss, misuse, unauthorised access and disclosure.
7. We may use your personal data for some or all of the following purposes:
• To deliver public services including to understand your needs to provide the services that you request and to understand what we can do for you and inform you of other relevant services;
• To confirm your identity to provide some services;
• To contact you by post, email, telephone or using social media (e.g., Facebook, Twitter, WhatsApp);
• To help us to build up a picture of how we are performing;
• To prevent and detect fraud and corruption in the use of public funds and where necessary for the law enforcement functions;
• To enable us to meet all legal and statutory obligations and powers including any delegated functions;
• To carry out comprehensive safeguarding procedures (including due diligence and complaints handling) in accordance with best safeguarding practice from time to time with the aim of ensuring that all children and adults-at-risk are provided with safe environments and generally as necessary to protect individuals from harm or injury;
• To promote the interests of the council;
• To maintain our own accounts and records;
• To seek your views, opinions or comments;
• To notify you of changes to our facilities, services, events and staff, councillors and role holders;
• To send you communications which you have requested and that may be of interest to you. These may include information about campaigns, appeals, other new projects or initiatives;
• To process relevant financial transactions including grants and payments for goods and services supplied to the council
• To allow the statistical analysis of data so we can plan the provision of services.
• Our processing may also include the use of CCTV systems for the prevention and prosecution of crime.
8. What is the legal basis for processing your personal data?
9. Sharing your personal data
• Our agents, suppliers and contractors. For example, we may ask a commercial provider to publish or distribute newsletters on our behalf, or to maintain our database software;
• On occasion, other local authorities or not for profit bodies with which we are carrying out joint ventures e.g. in relation to facilities or events for the community.
10. How long do we keep your personal data?
We will keep some records permanently if we are legally required to do so. We may keep some other records for an extended period of time. For example, it is current best practice to keep financial records for a minimum period of 8 years to support HMRC audits or provide tax information. We may have legal obligations to retain some data in connection with our statutory obligations as a public authority. The council is permitted to retain data in order to defend or pursue claims. In some cases, the law imposes a time limit for such claims (for example 3 years for personal injury claims or 6 years for contract claims). We will retain some personal data for this purpose as long as we believe it is necessary to be able to defend or pursue a claim. In general, we will endeavour to keep data only for as long as we need it. This means that we will delete it when it is no longer needed.
11. Your rights and your personal data
You have the following rights with respect to your personal data: When exercising any of the rights listed below, in order to process your request, we may need to verify your identity for your security. In such cases we will need you to respond with proof of your identity before you can exercise these rights.
(i) The right to access personal data we hold on you
(ii) The right to correct and update the personal data we hold on you
(iii) The right to have your personal data erased
(iv) (The right to object to processing of your personal data or to restrict it to certain purposes only
(v) The right to data portability
(vi) The right to withdraw your consent to the processing at any time for any processing of data to which consent was obtained
(vii) The right to lodge a complaint with the Information Commissioner’s Office.
You can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
12. Transfer of Data Abroad
Any personal data transferred to countries or territories outside the European Economic Area (“EEA”) will only be placed on systems complying with measures giving equivalent protection of personal rights either through international agreements or contracts approved by the European Union. [Our website is also accessible from overseas so on occasion some personal data (for example in a newsletter) may be accessed from overseas].
13. Further processing
14. Changes to this policy
Review date May 2020